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Investment Advisers

SEC3 offers an extensive suite of customizable compliance services for investment advisers, on either a one-time or recurring basis depending on your needs.

Examples of potential services include, but are not limited to:

  • Annual Compliance Reviews
  • Quarterly Compliance Reviews
  • Due Diligence Reviews
  • Risk Assessment and Gap Analysis
  • Compliance Testing and Analysis
  • Mock SEC Examinations
  • Compliance Training
  • Customized Compliance Services

Annual Compliance Review

For registered advisers, the Compliance Rule requires each adviser to review its policies and procedures, at least annually, to determine their adequacy and the effectiveness of their implementation. In Annual Compliance Review services, SEC3 can assist Chief Compliance Officers in every phase of the annual review process, from formulating a strategic plan, to conducting thorough assessments and testing of all aspects of the compliance program, to planning for next year's review. SEC3's Annual Compliance Review allows advisers to maximize available resources by fulfilling specific elements or the entire scope of the regulatory obligation. The Annual Compliance Review can conclude with a customizable, easy to read report and action plan.

Quarterly Compliance Reviews

Most advisers would prefer to diversify the strain on operational and financial resources of an annual review over the course of the year, which is why SEC3 offers its flagship service, the Quarterly Compliance Review, as the perfect solution. Quarterly Compliance Reviews conduct all the aspects of the annual review over the course of the year in manageable phases while revisiting critical and changing areas throughout the year. The dynamic scope and disciplined approach of Quarterly Compliance Reviews stimulates the evolution of the compliance program, keeping it continually current and addressing any issues as they appear. Quarterly Compliance Reviews optimize compliance resources and limit the interruption of your firm. Like the Annual Compliance Review, each Quarterly Compliance Review can conclude with a customizable, easy to read report and action plan.

Additionally, Quarterly Compliance Reviews address the essential, on-going demands of a compliance program, such as managing disclosure documents, filing requirements, and compliance policies and procedures. Quarterly Compliance Reviews provide the opportunity for SEC3's professionals to establish a deep partnership with each adviser and fund and actively participate in the compliance program.

Risk Assessment & Gap Analysis

The Risk Assessment & Gap Analysis not only fulfills regulatory expectations, it provides valuable insights into your risk profile and your exposure to those risks. SEC3's Risk Assessment & Gap Analysis is a system that considers the likelihood and impact of the compliance risk specific to each advisory firm or fund and assesses how well the existing controls mitigate those risks. The Risk Assessment & Gap Analysis report is a concise, but detailed summary in plain English that prioritizes risks by exposure, arming the Chief Compliance Officer and Independent Directors with the critical information to immediately implement an action plan.

Compliance Testing & Analysis

Forensic tests are the eyes and ears of the Chief Compliance Officer. Without rigorous, consistent forensic testing, a Chief Compliance Officer has no early warning systems. Various forensic tests are means to identify symptoms of potential compliance problems and can serve as confirmation that the compliance program is functioning properly. SEC3 can assist Chief Compliance Officers in designing and conducting a battery of rigorous and periodic forensic compliance tests as part of the continuous monitoring of the compliance program; including, but not limited to, trading and execution, portfolio compliance, code of ethics, account administration, and investment performance.

Mock SEC Examinations

Much of the fear surrounding a regulatory examination stems from the "unknown" element. A Mock SEC Examination is an effective process to gauge the types of exposures and concerns that an adviser or fund would face during a real regulatory examination. Mock SEC Examinations use current exam focuses, with proven exam approaches and methodologies, including interviews, reviews of policy and procedures, analysis, and testing, and conclude with a customizable summary of assessments, recommendations, and proposed solutions. SEC3's professionals, with years of experience as senior examiners with the Securities and Exchange Commission or as compliance professionals, provide expert insight and guidance. Mock SEC Examinations pierce the mystique of a regulatory examination and transform an often stressful experience into a valuable assessment process that allows a Chief Compliance Officer and the compliance staff to face a future regulatory examination with confidence and peace of mind.

Compliance Training

Drafting and adopting reasonable policies and procedures is only part of the successful implementation of a compliance program; effective compliance training is also essential. The success of a compliance program is predominately determined by the ability of the adviser's or fund's staff to consistently fulfill the goals and functions of the policies and procedures. SEC3's professionals will assist Chief Compliance Officers in developing and conducting customized training programs to your staff on the various aspects of your compliance program and their responsibilities under that program. Our belief is that training should rejuvenate the staff's awareness and sensitivity of compliance policies while reinforcing the importance of each person's role in the compliance program.

Other customized services include:

  • Development and Implementation of Customized Compliance Policies and Procedures
  • Compliance Calendar & Planning Assistance
  • SEC Examination and Inquiry Response
  • Deficiency Letter Response and Remedial Action Plans
  • Form ADV and IARD Filings and Reviews
  • Registration Assistance: State and Federal
  • Disclosure Reviews

Newsletter

Get the latest compliance news and insights - delivered weekly. The SEC3 Communique covers all compliance topics. CCO3 focuses on CCO topics.
tip: check both to keep informed!

Communiques

Pre-Dating & Back-Dating are Equally Risky

The SEC today suspended three accountants formerly of BDO USA LLP for improper professional conduct during its 2013 audit of AmTrust Financial Services Inc., an exchange-listed insurance company. According to the... read more »

Fiduciary Duty

On Friday, September 28, 2018 the SEC charged LendingClub Asset Management (LCA) and its former president Renaud Laplanche with fraud for improperly using fund money to benefit LendingClub Corporation (LendingClub),... read more »

Exciting Summer Project -- Dig Into Some Sand or Dig Into Your Firm's Best Ex Pr…

The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert July 11 targeting investment advisers’ most common deficiencies with regard to their best execution obligations under the Investment... read more »

SEC Adopts Fund Liquidity Reporting and Disclosure Changes

The final week of June was a busy one for SEC releases following the SEC’s June 28th open meeting. Among these was a revisit of Rule 22e-4 under the Investment... read more »

More SEC Settlements - This Time Form PF Filing Deficiencies

On June 1st, the SEC announced settlements with 13 RIAs who repeatedly failed to file Form PF reports. Most of these firms never filed over the review period (2012 through... read more »

Two Recent Enforcement Actions Against Private Fund Advisers

The industry should not misinterpret the SEC’s 2018 National Exam Program Priorities as a shift away from private fund advisers. As discussed during the SEC’s recent National Compliance Outreach Seminar... read more »

Events

Chief Compliance Officer Roundtable: Breakfast Briefing - November 8, 2018

When: November 8, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Dorsey PF 2018 Symposium

When: September 26, 2018 (8:30 am - 6 pm Where: Dorsey & Whitney LLP | 51 W. 52nd Street | New York, NY 10019 Directions > SEC3’s President, Janaya Moscony will join...

Chief Compliance Officer Roundtable: Breakfast Briefing - June 14, 2018

When: June 14, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Webinar: 2018 SEC Exam Priorities & Recent Exam Highlights

Don’t miss the opportunity to meet with us in person to discuss the topics that matter most to you. Tobin S. Cochran, Managing Member/President of Focus 1 Associates, LLC and...

Chief Compliance Officer Roundtable: Breakfast Briefing - February 7, 2018

When: February 7, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Upcoming Events - September & October 2017

Upcoming Events Don’t miss the opportunity to meet with us in person to discuss the topics that matter most to you. SEC3 is teaming up with industry experts in NYC to discuss...

May 23, 2017 - Webcast: WannaCry Ransomware: Were You Really Protected or Just L…

When: Tuesday, May 23rd, 2017 | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. We...

June 14, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Willkie Farr & Gallagher LLP | 600 Travis Street | Suite 2310 | Houston, TX Barry Barbash from Willkie Farr & Gallagher LLP,...

June 13, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Haynes and Boone, LLP | 2323 Victory Avenue | Suite 700 | Dallas, TX 75219 Validated parking is available in the garage attached...

May 31, 2017 - Chicago

9:00-9:30 a.m - Networking and Continental Breakfast 9:30-11:00 a.m - Program Location: Baker & McKenzie LLP | 300 East Randolph Drive | Suite 5000 | Chicago, IL 60601 Kristin Gonzalez and Jerome Tomas...

May 17, 2017 (NYC WIMF)

This event is by invitation only. Please email info@seccc.com to learn more.

May 15, 2017 (NYC Chief Compliance Officer Roundtable)

9:00-9:30am - Networking and Continental Breakfast 9:30-11:00am - Program Location: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone:...

Webcast: The Most Insidious Cybersecurity Threat Is Also The Least Understood

When: Tuesday, April 25th | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. Ransomware, the...

CCO Liability (Part III): Managing Liability Webinar

In this webinar, panelists discuss indemnifications and insurance as potential remedies to address the direct financial risks to a CCO. Attendees will learn: What terms and conditions should Chief Compliance Officers be...

Webinar: CCO Liability (Part III): Managing Liability: Navigating Indemnities an…

When: Tuesday, February 21, 2017 Schedule: 11:00am ET / 10:00am CT / 9:00am MT / 8:00am PT / 7:00am AT Description of Webinar: The National Society of Compliance Professionals is pleased to host...